msb registration

Section 6: MSB Registration
MSB REGISTRATION
As an agent, you should have already worked with your MoneyGram Sales and Compliance
Representatives to determine if you should register as an MSB. MSB registration should occur
within 180 days after the date on which the MSB is established.
Below are additional guidelines provided by FinCEN to consider:
This guidance concerns Bank Secrecy Act requirements under current regulations for the initial
registration, and registration renewal, of money services businesses.
The definition of money services business includes each agent, agency, branch, or office within
the United States doing business, whether or not on a regular basis or as an organized
business concern, in one or more of the following capacities:
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Currency dealer or exchanger
Check casher
Issuer of traveler’s checks, money orders or stored value
Seller of traveler’s checks, money orders or stored value
Money transmitter, regardless of the amount of money transfer services offered
A person who does not offer one or more of the financial services specified in (1) through (4) above in an amount
greater than $1,000 in currency or monetary or other instruments for any person on any day in one or more
transactions is not included in the definition of money services business.
Businesses defined as money services businesses (31 C.F.R. § 103.11(uu)), generally are
required to register with the Financial Crimes Enforcement Network whether or not they are
licensed as money services businesses by any state.
Initial registration is accomplished by filing FinCEN Form 107 electronically via the internet.
YOU CANNOT PRINT and mail the form.
To use the BSA E-File System, you must first register online as a business entity. See
the following pages for additional directions.
REGISTRATION RENEWAL
MSG registration renewal is required every 2 years by December 31st for as long as the
business continues to meet the definition of a money services business. Registration renewal is
accomplished by E-Filing FinCEN Form 107, Registration of Money Services Business, and
checking box 1b, renewal.
MoneyGram Interna onal has compiled this informa on as a courtesy to our Agents directly from the FinCEN website and therefore is not
responsible for the content. Final process and decisions are made by FinCEN and not MoneyGram Interna onal or it’s affiliates. MoneyGram
Interna onal cannot guarantee all informa on is current.
Section 6: MSB Registration
USING THE BSA E-FILE SYSTEM
What is the BSA E-File System?
The BSA E-Filing System supports electronic filing of Bank Secrecy
Act (BSA) forms (either individually or in batches) through a FinCEN
secure network. BSA E-Filing provides a faster, more convenient,
more secure, and more cost-effective method for submitting BSA forms. Additional benefits are listed under Using BSA E-Filing.
How does BSA E-Filing work?
The BSA E-Filing System is hosted on a secure website accessible on the Internet. Organizations that file BSA forms with FinCEN can securely access the system AFTER
they apply for and receive a user ID and password from FinCEN. In addition, individuals
can apply for and receive a user ID and password from FinCEN to file the FBAR report.
Become a BSA E-Filer
To become a BSA E-Filer, Agents MUST first register with FinCEN as a business entity.
NOTE: This is NOT registering as a MSB. This step simply gives Agents access to the BSA E-File
system and IS REQUIRED.
Step 1: Register with FinCEN (This step could take several minutes.)
1.) From any computer with internet access, go to the FinCEN E-File website at:
www.bsaefiling.fincen.treas.gov/main.html
The following screen will appear:
2.) Click on “Become a BSA E-Filer” as shown above.
Section 6: MSB Registration
The next screen will ask you to select 1 of 2 options indicating they type of E-Filer you
wish to enroll as. Once you have selected an option and completed registration, you
cannot change your selection without starting completely over.
3.) Select one of the “How are you enrolling?” options.
Click on this icon to register and submit forms as a business. This icon should
be used by both large institutions (such as publicly traded corporations) and
small institutions (such as unincorporated sole proprietorships, personal
service corporations, or similar small business entities), whether they are
financial institutions (such as banks, insurance companies, money services
businesses, broker-dealers, and casinos) or non-financial institutions (such as
dealers in precious metals, car dealers, or any other types of business).
Please proceed to Page 3 if you are enrolling as an Instituion
Click on this icon only to enroll as an individual and submit an FBAR as an
individual rather than a business.
Please proceed to Page <Holder> if you are enrolling as an FBAR Filer.
Section 6: MSB Registration
4.) If you selected “Institution” filer, the following screen will appear:
Follow EACH step provided on this screen, completing each one before proceeding to the next.
Identify Your Organization's Point of Contact
Clicking on Step 1 will allow you to read what is required of your organizations
Point of Contact for all FinCEN E-Filing. READ everything on this page. No
action is input is required on the computer for this step. However, before
proceeding to Step 2, you will need to know the name and contact information
for the selected contact.
Section 6: MSB Registration
Once you have read the requirements of Step 1 on the FinCEN site and have recorded
the contact information, click on the Step 2 link at the bottom of the page.
Fill Out and Submit the Supervisory User Application Form
Clicking on Step 2 will begin the REQUIRED process of selecting a system user
ID to access the secure portion of the BSA E-Filing System.
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It is suggested that you print this screen.
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Read the directions and REQUIRED information on this page and then click
on the Supervisory User Application Form link, as shown below:
Section 6: MSB Registration
Clicking on the Supervisory User Application Form link will open a form that needs
to be completed online.
REQUIRED Information is typed directly into the fields.
Fields are described on the previous web page before this form. It was previously
suggested that you print that page.
 Completing this form will also create your USER ID which will be required for future
access.
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After checking for accuracy and completing the form:
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Read the WARNING box at the bottom of the page.
Check the I AGREE box to confirm your agreement with the policy
Click the SUBMIT button as shown above.
Section 6: MSB Registration
Obtain Authorization as Supervisory User
Clicking on Step 3 continues the process to authorize you as a Supervisor User on
your account.
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As the Supervisory User, you are responsible for completing the remaining steps of
the enrollment process.
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After you submit your Supervisory User Application Form, FinCEN will process your
application and provide an e-mail confirmation to you with a confirmation link.
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Please click on the confirmation link CONTAINED IN THE EMAIL within five calendar days to complete your account setup.
The confirmation link will provide your BSA E-Filing login and connect you to the BSA
E-Filing System.
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Click on the I AGREE button to accept the terms of the FinCEN system.
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You will be asked to create a Password
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Note: The Password requirements are VERY SPECIFIC. Please makes sure you
are following the directions as you set up your password.
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Once your password has been accepted, you will be asked to log on.
Section 6: MSB Registration
Download the Forms Reader
Clicking on Step 4 provides directions to confirm that you have the correct software
(Forms Reader) to use the E-File system.
Adobe Reader is 9.1 or 10.0.2 is required for E-Filing
To determine what version of Adobe Reader is installed on your computer (if any), follow these instructions:
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Go to your Start Menu.
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Select Settings and then Control Panel.
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In the Control Panel window, select Add or Remove Programs.
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A list of your currently installed programs will be displayed.
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If you see Adobe Reader 9.1 or 10.0.2 in the list, you have the required software.
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If you do not have this software or specific version on your computer, you may
download it for free directly from the Adobe website or through FinCEN's website
and click on the link under Forms.
Who to Contact for Additional Help
For E-File technical questions:
[email protected]
For regulatory inquiries related to form completion or selection:
[email protected]
For form completion or selection issues specific to FBAR:
[email protected]
For law enforcement related matters:
[email protected]
314 Inquiries from Law Enforcement:
[email protected]
314 Inquiries from Financial Institutions:
[email protected]
General FinCEN Inquiries:
[email protected]
For any other matters, you can also send your inquiry to [email protected].
Section 6: MSB Registration
At this point, you will be ready to E-File your Form 107 for MSB Registration.
How do I submit my RMSB through BSA E-Filing?
Once your institution is enrolled in BSA E-Filing, you will be able to select the “File FinCEN
RMSB” link from the BSA E-Filing Home page under “Reports.” Please fill out all the
information requested on the report, just as you would have done on the paper form.
Embedded instructions for filling out the report are available by placing the pointer from your
mouse over each data field. Additionally, the BSA E-Filing System will highlight any errors or
critical missing information so they can be corrected or added before you can complete your
submission.
After you fill out the online RMSB on the BSA E-Filing System, you will need to digitally sign
your RMSB by clicking on “Sign with PIN.” Your PIN was assigned to you during enrollment
and would have been emailed to you. If you cannot obtain your email with your PIN, you can
also click on the “Manage PIN” link within the BSA E-Filing System to view your PIN.
After digitally signing your PIN, you will then click on “Save” to save a copy of your RMSB. You
must save a copy of the RMSB for the “Submit” button to become available. After saving, click
on “Submit” to submit your RMSB to the BSA E-Filing System.
How do I validate my RMSB was received and processed by the BSA E-Filing System?
After digitally signing, saving, and submitting an RMSB, a confirmation pop-up window will
appear with your BSA E-Filing System tracking ID (this is not your registration number), as
well as the date/time submitted to the BSA E-Filing System. You will also receive an email
confirmation indicating your filing was Accepted by the system.
The status of your filing can also be viewed by clicking the “Track Status” link within the BSA E
-Filing System. The initial status will be Accepted and within two business days the status will
change to Acknowledged and a Secure Message will be sent to your Inbox with a message
containing your registration number.
A sample of the message is displayed below:
Section 6: MSB Registration
How do I view my registration information and print out a copy for my records?
Certain registration information will be added to FinCEN's MSB Registrant Search Web page
within approximately two weeks of electronically filing the Registration of Money Services
Business (FinCEN Form 107) on the BSA E-Filing System. Acknowledgement letters will not
be sent to MSBs. Please visit the MSB Registrant Search Web page (http://www.fincen.gov/
financial_institutions/msb/msbstateselector.html) to view and print your MSB registration
information.
Will I receive a receipt for my filing?
Yes, once your form is submitted, you will receive a confirmation from BSA E-Filing that it was
accepted for processing. Within two business days you will then receive a message from the
BSA E-Filing System that provides acknowledgement that your submission was received and
processed. This message can be viewed by logging into the BSA E-Filing System and
selecting “View Inbox” under the “Secure Messaging” section. This second message will
include the MSB Registration Number associated with your registration. Within approximately
two weeks, your registration information will appear on FinCEN’s MSB Registrant Search Web
page. We strongly recommend saving your original registration submission and the
acknowledgements on your computer or by printing paper copies for your records.
Will paper RMSB forms still be accepted?
No, as of July 1, 2012, FinCEN no longer accepts paper RMSB forms. All RMSB forms must
be submitted using the BSA E-Filing System.
Are there penalties for not registering as an MSB?
Yes, there are possible civil and criminal penalties for failure to register.
Where can I find more information about E-Filing?
More information about E-Filing and its benefits can be found in the Frequently Asked
Questions section on the BSA E-Filing System home page or by contacting the BSA E-Filing
Help Desk at 1-866-346-9478 (Option 1). Hold times will vary.